Compliance with the CCTS’ Public Awareness Plan

Download one page report card

Canadians need to be aware of or be able to easily find out about the CCTS when they need help in resolving disputes with their service providers. We take seriously the continuing need to ensure public awareness of the services that we provide.

Participating Service Providers (PSPs) must comply with Developing Public Awareness of the CCTS (the Public Awareness Plan) and promote awareness about the CCTS to their customers.

To ensure PSP compliance, the CCTS conducts a review each year to:

assess compliance and identify any instances of non-compliance,
engage with PSPs that have non-compliance issues to ensure that issues are addressed in a timely manner, and,
take enforcement action against PSPs that do not comply.

This report card highlights our findings about PSP compliance with the Public Awareness Plan from January 1 to December 31, 2023.

Requirements

The Public Awareness Plan requires PSPs to inform their residential and small business customers about the CCTS in English and French in the following:

Our approach

Our goal is to encourage compliance through educating and engaging PSPs.

The CCTS annually audits:

PSP websites: a review of all PSPs that are audited to ensure that the website has all of the required CCTS information available for customers.
PSP documentation: a review of PSP invoices, white pages, and internal documents about the PSP’s complaint-handling process for the 25 PSPs that generated the most CCTS complaints.

The CCTS shares its audit results for each audited PSP with the PSP. When we find issues of non-compliance, we contact the PSP and provide an explanation, requesting the PSP to identify how and when it will come into compliance. Our Compliance team works with PSPs until all identified issues have been resolved and we publicly identify any service providers who refuse to comply. Additionally, starting in 2023, we provide an annual reminder to all PSPs about their obligations under the Public Awareness Plan.

PSP websites

In 2023, the CCTS audited 51 PSPs^[1] to ensure their customers have access to the required website information and found 15 out of 51 (29%) audited PSPs did not have any information about the CCTS on their websites. This is consistent with the results from the last three years (28 – 32% compliance). The providers without information about the CCTS on their website in 2023 were primarily small PSPs. We collaborated extensively with those providers and as a result, 10 out of 15 small PSPs have now added the required information.

Although most audited PSPs had information about the CCTS on their website prior to being audited, many of the issues we found were about how and where the CCTS information was presented. Overall audit results are in the below.

Trends Observed

The CCTS highlights some of the trends seen in the past few years of our Compliance Program.

Trend 1: PSPs are more compliant with website requirements

Overall, there is an increase in PSP compliance with the website requirements. In 2019, only 14% of the audited PSPs were fully compliant and in 2023, 35% of the audited PSPs were fully compliant.

Figure 1.1: PSPs compliance with website requirements – year over year

Trend 2: The majority of PSP websites did not return search results for CCTS

In 2023, 15 out of 29 PSP websites (52%) that had a search function did not return results with CCTS information when searching for all keywords related to “complaints” and “CCTS”. In 2022 it was 55% and in 2021, it was more than 70%. While PSPs have become more compliant with the search requirement over the past couple years, this will be an important area for our compliance efforts to focus on.

The search function on a PSP website is an important tool customers use to find information. PSPs must ensure that using the search function on their websites result in providing the required CCTS information to customers on residential, small business, French and English websites. If search results do not display CCTS on all of a PSP’s websites, then the CCTS considers the PSP as non-compliant. The CCTS has reminded PSPs each year in our Compliance Monitoring Report about the search function requirement and this year we notified all PSPs they should check their websites to ensure compliance and that we would name those PSPs who were repeatedly non-compliant. Despite this messaging, we continue to see non-compliance with the search function requirement.

In the past 4 out of 5 years, Rogers and TELUS were non-compliant with the website search function requirement. The main issue for both PSPs was that searching their business websites did not result in the required CCTS information. Another issue has been missing key words on their French and English residential websites. Overall, this is concerning given that Rogers and TELUS have been audited for compliance with the Public Awareness Plan since 2017 and they are well aware of this requirement.

PSPs can ensure compliance with the search function requirement by implementing an internal control processes for website updates. Given the limited improvement and significant recurrence, we urge all PSPs to implement internal processes and regular checks to ensure that website updates do not change the search function.

Trend 3: Almost half of the PSP complaint websites weren’t easy to find or clearly labelled

The CCTS information on 23 out of 51 PSP complaint websites (45%) was either not easy to find or not clearly labelled. Many of the non-compliant PSPs were smaller service providers (20 out of 23) who buried the CCTS information somewhere on their website where customers would not likely find the information, for example, in the fine print of their privacy policy or terms of service. Over the years, we’ve provided guidance to all PSPs and given examples of how to clearly label the complaint page and make it easy for customers to find information about the CCTS. We encourage all PSPs to carefully review the CCTS’ guidance and check that its websites adhering to those guidelines.

Conclusion

Ensuring PSPs are compliant with the CCTS’ public awareness requirements is fundamental for customers to be able to easily find out how they can get help with unresolved telecommunications and television issues. The CCTS has annually checked PSP compliance with this requirement and will continue to engage with more PSPs to ensure they fulfill their responsibilities to promote awareness of the CCTS.

Appendix: Developing Public Awareness of CCTS

Appendix: Developing Public Awareness of CCTS (PDF)

Footnotes

This included:
- The 25 PSPs that generated the most CCTS complaints in the previous year, as listed in the 2022-2023 Annual Report. These PSPs accounted for 95% of all accepted complaints.
- 5 PSPs identified as non-compliant in 2023. Throughout the year, the Compliance team engages with PSPs for specific non-compliance issues requiring engagement.
- 21 randomly selected PSPs (previously unaudited). This category ensures that all PSPs, regardless of their size and compliance status, can be reviewed from time to time to determine their compliance with the Public Awareness Plan requirements. Including this year, the CCTS has audited the websites of 209 PSP brands since 2018.